The Andhra Pradesh High Court has quashed an assessment order covering multiple financial years — holding it unsustainable both because it is a composite order covering five separate tax periods without individual period-wise adjudication, and because the Summary Orders (Form GST DRC-07) were unsigned. The ruling, by Justice Ninala Jayasurya and Justice T.C.D. Sekhar in Writ Petition No. 20567/2026 (VNR Traders v. Superintendent of Central Tax, Ongole, decided 28.07.2026), follows the coordinate bench precedent in SRK Enterprises (2023) and is disposed of without even calling for a counter affidavit.
The assessment context involves VNR Traders, a registered dealer, which received a single assessment order dated 11.12.2025 covering FY 2019-20, 2020-21, 2021-22, 2022-23 and 2023-24. The petitioner challenged the order on multiple grounds: non-compliance with Rule 142(1A)'s requirement of pre-assessment intimation, the composite order structure, and the absence of signatures on the Summary Orders. On the merits, the petitioner also claimed to have a good case, but the court did not need to examine that.
The Division Bench accepted the challenge on the composite order ground without requiring the Revenue to file a counter affidavit. The ratio is straightforward: each financial year is a distinct assessment period with its own liability, facts, and legal issues; combining them into a single order without period-specific adjudication prevents the affected party from meaningfully contesting each year's liability and conflates distinct proceedings. A coordinate bench had taken this view in SRK Enterprises (W.P. No. 29397/2023, 10.11.2023). The court also noted the absence of signatures on the Summary Orders — a further independent ground for invalidity, since unsigned orders have no legal efficacy.
The order was set aside subject to the petitioner depositing 20% of the disputed tax within four weeks. The Revenue retains liberty to pass appropriate orders for each tax period separately, after issuing individual notices per period and affording opportunity of hearing. The ruling adds Andhra Pradesh to a growing list of High Courts — Karnataka, Delhi, Madras, Rajasthan — that have held composite multi-year assessment orders unsustainable.
2026-juristway.com-2345-HC(Andhra Pradesh)-GST | High Court of Andhra Pradesh (Division Bench) | Writ Petition No. 20567/2026 | 28.07.2026